Privacy Principles

We are deeply committed to creating a safe and secure online environment for you & your children.

We do not sell your Personal Information to advertisers. Ever.

We make it easy for:

Teachers to choose to share information & progress with a child’s parents

Schools to choose to share structure (lessons, forms, etc.)
with other schools

Teachers & staff to access the information they need to do their job

We make it hard for:

Anyone to unknowingly share any information with anyone else

We don’t show your child’s progress to other parents

Privacy Policy

We’ve done our best to write this policy in simple, clear terms. We’ve also added a column on the right that provides short explanations of the legal language in plain English. While these explanations are intended to aid in your understanding of our privacy practices, they are not legally binding and you should read both our Terms of Use and this Privacy Policy carefully.

Last updated: July 22, 2017.

In human words:

You agree to the following if you choose to use Transparent Classroom.

1. Introduction

This Privacy Policy explains how Lightsmith Consulting LLC, dba Transparent Classroom collect and use your information. This Privacy Policy is a binding contract and by using our Transparent Classroom software (our “Service”) you agree to it.

In human words:

Schools tell us about themselves and their students, parents, and staff. Individuals also tell us about themselves. Any information we aggregate and anonymize isn’t personal information.

2. Personal Information We Collect

In order for you to register with us, your school must provide us with your name and email at a minimum. You may also have chosen to provide other Personal Information like a profile photo or address. If you are a school, we may also collect your payment information, mailing address, telephone number and other information about your school. We allow schools to provide us Personal Information about their students including name, age, gender, and regular hours in school. Schools can also invite parents by providing us with parent name and email. For some schools, we also collect attendance records. For some schools, we also collect online forms filled out by parents. We may refer to this information, collectively, as “Personal Information” in this Privacy Policy.

Personal Information does not include information that cannot be used to identify you, such as internet protocol (“IP”) address, browser type, internet service provider, operating system, or device type, or information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.

In human words:

We may store information about where you go on our site and how you get there in order to improve our site.

3. Non-Personal Information We Collect

We may collect non-personally identifiable information about you that is not Personal Information. When you access our website, we may collect such things as your IP address, browser, operating system, referring URL, and other general information about our visitors. This information, on its own, cannot usually be used to identify you. This information is used for internal analysis to monitor and improve our site.

In human words:

Schools publish most of the information you may care about. If there are any issues about the content of the information, feel free to talk to them directly about it.

4. Information Published by Schools

Schools use our Service to publish observations, notes, photos of the classroom, child progress, conference reports, lessons, and forms for parents to fill out.

The schools who subscribe to our Service are responsible for their own publications, we simply provide the Service. You agree that we cannot be held liable for the information that the school collects or publishes using our service. If you have any concerns, we recommend that you go to the source, which is the school.

In human words:

We use this information to talk to you and give you a better experience. You have the opportunity to opt out of some of these communications.

5. Use of Information

5.1 Provide, improve and develop the Service.

We are able to deliver our Services, personalize content, and make suggestions for you by using this information to understand how you use and interact with our Services.

We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.

5.2 Communicate with you.

We use your information to communicate with you about our Services and let you know about our policies and terms. We also use your information to respond to you when you contact us. We use your payment information to process transactions. If you no longer wish to receive certain communications from us, you may opt-out of receiving them by following the unsubscribe instructions included in each communication or by emailing us at info@transparentclassroom.com. However, you will not be able to opt-out of all communications, such as those legally required notices or required Service notices.

5.3 Choice and opt out.

We provide you with the opportunity to opt out of having your Personal Information used for certain purposes when we ask for this information; however, this may limit your ability to fully use our Service. You may also update your personal and security preferences by signing in to the Service. You may also opt out of email and promotional communications by following the instructions included in each such communication or by emailing us at jeremy@transparentclassroom.com.

In human words:

In general, school staff can see everything about all parents and children in the school, parents are mostly only able to see info about their own children, except where other parents have chosen to share contact info. In many cases, you can choose what personal information we keep about you and how your information is used and shared.

6. Sharing Information

6.1 What can other staff in the same school see?

Administrators within Transparent Classroom can see all the information published to and by Transparent Classroom within their school. This includes all student records across the school, parent information, and even parent browsing history within our Service. Teachers within Transparent Classroom are allowed to see all information associated with their classrooms.

The directory shows you which staff members are Administrators and which are Teachers. It also shows you which classrooms a teacher has access to.

6.2 What can a child’s parents see?

Parents can see:

Any non-private teacher observation made about their child

Any non-private photo their child was tagged in

Their child’s progress through lessons (unless the school disables this feature)

All published conference reports, forms, and attendance records we keep about their child

As a Parent, you have the right to access all Personal Information included in the items described in this Section 6.2. You may access such Personal Information through the Transparent Classroom website. Further, you may edit and delete some of the Personal Information we collect through the Transparent Classroom website.

6.3 What can other parents see?

Parents with children in the same classroom can see:

Other parents’ names and profile photos (unless school removes their children from directory)

Other parents’ children’s names, ages, and profile photos (unless school removes children from directory)

Contact information those parents have not marked private including phone, email, and address

Non-private observations and photos of another child IF AND ONLY IF both their child and the other child were mentioned in the same observation or tagged in the same photo.

Parents with children in the same school but different classrooms don’t have access to any of this information.

6.4 What can other schools see?

Parents and staff are not allowed to see any information associated with any parent or child from a different school.

The information one school is allowed to share with other schools is:

Lessons (names, descriptions, ordering and grouping)

Conference Report templates

Form templates

6.5 Who else can see your information?

In order to provide excellent and timely customer support, Transparent Classroom staff have the ability to look at all the information in the system.

Generally, if you would like to further limit the use or disclosure of your Personal Information as set forth in this Section 6, or if you would like to request a copy of your accessible Personal Information, please contact jeremy@transparentclassroom.com.

In human words:

We use cookies, like everyone else does :).

7. Cookies

When you use the Service, we may collect certain information by automated or electronic means, using technologies such as cookies, browser analysis tools, and web server logs. As you use the Service, your browser and devices communicate with servers managed by our business partners, our services providers or us to record the interactivity and to fulfill your requests for services and information.

A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Service. Some cookies contain a signature that allows us to connect your activity with other information we store about you in your profile or as related to your interactions with the Service. The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or devices, which are then transmitted back to our Service by your computers or devices. We use cookies to keep track of how you are using our site so that we can tailor our content to your interests

Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences (e.g., the way Service pages or information is displayed).

We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access the Service, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the IP addresses of the devices you use to interact with the Service. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you accessed the Service and the websites you visit after you leave our Service, if this information is supplied to us by your browser.

In many cases the information we collect using cookies and other tools is used in non-identifiable ways and without any reference to Personal Information. For example, we use information we collect about users to optimize the Services and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information.

In human words:

We WON’T sell or rent your or your child’s info, unless our entire company is sold or acquired. We DO work in concert with service providers that might need some of your info in order to do their job.

8. Third-party Access to Your Information

First and foremost, you should know that Transparent Classroom does not sell or rent your (or your child’s) Personal Information to any third party for any purpose - including for advertising or marketing purposes. Third-party advertising is not permitted on Transparent Classroom. Furthermore, we do not share Personal Information with any third parties except in the limited circumstances described in this Privacy Policy.

8.1 Service Providers

We work with vendors, service providers, and other partners to help us provide our Service by performing tasks on our behalf. We may need to share or provide information (including Personal Information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. Generally, these service providers do not have the right to use your Personal Information we share with them beyond what is necessary to assist us. These service providers must adhere to confidentiality and security obligations in a way that is consistent with their own terms and policies.

Transparent Classroom is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU or Switzerland, including onward transfer liability provisions.

This Privacy Policy only applies to information collected during your use and access of the Service or any other interactions you may have with Transparent Classroom. Our Service contains links to other locations on the internet that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of other websites or services. We encourage you to read the privacy statements of each website that collects your Personal Information.

8.2 Merger, Acquisition or Sale

We may also disclose your Personal Information to effect a merger or acquisition or to support the sale or transfer of business assets. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice via the Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

In human words:

We might have to share some of your info if the FBI tells us to or we think something illegal is going on. We will still try to do the right thing, though.

8.3 Law Enforcement

We may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of investigating, preventing, or taking action regarding suspected or actual illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, to comply with subpoenas, or as otherwise required by law. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either.

In human words:

We strive to keep your information safe.

9. Security

Transparent Classroom uses reasonable administrative, technical, and physical security measures to protect data about Transparent Classroom customers. Transparent Classroom stores your Personal Information and other data on servers located in the United States. If you would like to know more, please email jeremy@transparentclassroom.com.

Please be aware that you are responsible for maintaining the strict confidentiality of your account login credentials, and for any activity that occurs under your account credentials. Please notify us if you suspect any unauthorized use of your account or other breach of security.

In human words:

California has all these rules, we play by them.

10. California Online Privacy Protection Act

We permit residents of California to use our service, and fully comply with California’s privacy laws. If you have any questions about your rights under this Privacy Policy, please contact us for more information at jeremy@transparentclassroom.com.
> In human words:
>
> We have chosen to comply with the Privacy Shield Frameworks and are therefore GDPR compliant.

11. Privacy Shield

Lightsmith Consulting LLC, dba Transparent Classroom, complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Transparent Classroom has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission has jurisdiction over Transparent Classroom’s compliance with the Privacy Shield.

The EU-US Privacy Shield Framework incorporates the principal EU General Data Protection Regulation (GDPR) requirements covering access, disclosure, security and transparency of personal data, and allows U.S. companies, and EU entities working with U.S. companies, to meet the requirements of the GDPR. This means Transparent Classroom’s EU-based users can share personal data with us and remain compliant with the GDPR.

We are committed to protecting your privacy in compliance with the Privacy Shield Principles. EU and Swiss Individuals with inquiries or complaints regarding our Privacy Policy can contact us at jeremy@transparentclassroom.com.

If you do not receive a timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, complaints may be referred to the International Center for Dispute Resolution / American Arbitration Association (ICDR/AAA), as the independent recourse mechanism chosen by Transparent Classroom in compliance with Privacy Shield. You may get more information or contact ICDR/AAA at http://go.adr.org/privacyshield.html. The services of ICDR/AAA are provided at no cost to you.

Under certain conditions, individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted. Please see the Privacy Shield website for more information, https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
> In human words:
>
> If you’re in Australia and represent a school, you should obtain informed consent from your parents to use Transparent Classroom.

12. Notice to Schools - Australia Privacy Principles

Prior to use of Transparent Classroom in Australia, informed consent must be provided by the parents of each child in your school that their child’s data will be transferred beyond the borders of Australia through the Service. Parents must be notified prior to providing consent that if consent is given to the overseas disclosure, the schools will not be required to take reasonable steps to ensure that Transparent Classroom complies with Australian Privacy Laws.

In human words:

We may change this from time to time.

13. Amendments

We may modify the terms of this Privacy Policy from time to time. In the event of any material change to our Privacy Policy, in Transparent Classroom’s sole discretion, you may be notified by email of such change, if you are registered user of the Service. If any change is unacceptable to you, you should immediately cease use of the Service. Your continued use of the Service following a notice of a change in the Agreement via the Service will constitute your binding acceptance of the changes.

In human words:

Ask us if you have questions!

14. Comments and Questions.

If you have any comments or questions, you may address them to Transparent Classroom, 5470 Shilshole Ave NW, Seattle, WA, 98107, or by email at info@transparentclassroom.com.